Lebanon, Hanover Re-Evaluating Wastewater Arrangement

Lebanon —City officials raised concerns last week about traffic congestion in the expanding Route 120 corridor between Lebanon and Hanover, but added development in the area could also lead to problems underground.

Constraints in the wastewater infrastructure that supports the northern portion of the corridor have been compounded by uncertainties from state and federal environmental regulators, leading public officials to consider a shake-up in what has long been a largely informal arrangement between the two municipalities.

An agreement reached earlier this year between the city of Lebanon and the town of Hanover established a maximum threshold of wastewater flow for the first time since Lebanon first started sending sewage to Hanover for treatment in the late 1960s. The agreement also requires Lebanon to develop a contingency plan by the end of next year that would outline the steps needed for the city to redirect its wastewater to its own facility, should Hanover decide not to accept the city’s wastewater any longer, or to accept only a portion.

“There are certain limited resources that we have,” said Andrew Gast-Bray, Lebanon’s planning director. “It’s a lot harder than you think. There are a lot of moving parts that work together and have an impact on each other.”

The Hanover wastewater treatment plant is just off the Mink Brook near the Pine Knolls Cemetery, downhill from the northern portion of the corridor. Lebanon’s facility is along the Connecticut River in West Lebanon, near the new Hannaford supermarket.

All of the land in the Route 120 corridor — from the Centerra complex and Dartmouth-Hitchcock Medical Center to the Hanover border — sits in the Gile watershed, which is beyond the “point of gravity” for Lebanon wastewater, meaning far less infrastructure is required to send the sewage to the Hanover facility. Development in the watershed, along with the Sachem Village area just south of Hanover off Route 10, makes up about a third of Hanover’s wastewater intake.

Peter Kulbacki, Hanover’s public works director, said the development potential of the land in the northern section of the Route 120 corridor could bring about two times more wastewater flow than Hanover has the potential to treat in its facility.

The agreement reached this year puts the maximum flow of Lebanon wastewater to the Hanover facility at 650,000 gallons a day, on average, which Kulbacki said represents the amount of excess capacity at the Hanover facility. It also sets in place discussions between the two municipalities about future wastewater planning, to be triggered when Lebanon reaches 80 percent of that capacity, or 520,000 gallons a day.

On average, Lebanon sends about 210,000 gallons of wastewater a day to Hanover for treatment, with about 160,000 gallons coming from DHMC alone, according to Lebanon’s utilities superintendent, Carl Colburn.

The proposed Altaria business park just south of the Centerra complex — which would include a 120-unit hotel, more than 300,000 square feet of office and research space, 42,000 square feet of retail space, and up to 160 residential condominiums — is projected to add about 112,000 gallons a day to that number over its full 20-year buildout. Altaria is nearing the end of its review process with the city’s Planning Board, and the first phase of the two-phase project has already been approved.

According to Kulbacki, the Hanover treatment plant is operating well below its treatment capacity of 2.3 million gallons a day. But potential regulatory changes to treatment processes could lower the quantity of wastewater that the plant is able to handle. “At some point, we may have to say we can’t take it,” Kulbacki said. “It wouldn’t be because we have no capacity, it would be because we can’t treat it.”

Changes handed down by environmental regulators, he said, could completely alter the town’s wastewater management strategy.

“All of these things are basically a snapshot in time,” said Kulbacki. “And things can change.”

A Developing Picture

Stressing the uncertainties in environmental regulations for wastewater treatment, Kulbacki pointed to similar situations in nearby communities.

In February 2010, the Environmental Protection Agency objected to a Hartford wastewater permit, citing the need for the town to monitor the levels of nitrogen in the treated wastewater it discharges into the Connecticut River.

John Choate, Hartford’s utility superintendent, said the plant now monitors for the organic compound, which it never before had to do, because language regarding nitrogen had been added to its permit. At the time, Hartford was in the process of a $14 million upgrade, which made its treatment facilities capable of nitrogen and phosphorus removal.

“We anticipated the limits,” said Choate, who described Hartford as the “lead puppet” in a wave of new permitting trends for communities that discharge wastewater into the Connecticut River.

A coalition of municipalities in New Hampshire’s Seacoast region is planning to sue the Environmental Protection Agency over what it sees as unreasonably low nitrogen and phosphorous limits, which could necessitate tens of millions of dollars in upgrades to the region’s wastewater treatment facilities.

Environmental regulators are in the process of rewriting Hanover’s five-year wastewater discharge permit, and public works officials in the town expressed concern that a situation similar to that on the Seacoast could develop in the Upper Valley in coming years. “Just given the climate with the (Environmental Protection Agency) right now, we have no idea what to expect,” said Kevin MacLean, superintendent of Hanover’s water reclamation department.

According to MacLean, “everything is hinged” on the renewal of Hanover’s five-year state Department of Environmental Services permit. A potential tightening on acceptable levels of nitrogen in Hanover’s wastewater “might drive discussions about diverting flow, or redistributing it, sooner rather than later,” said MacLean. “It’s kind of a moving target.”

Stergios Spanos, supervisor of permits and compliance at New Hampshire’s Department of Environmental Services, said the agency last issued permits to both Lebanon and Hanover in 2006, which means Lebanon is “fair game” for regulators, although the city has not yet been tapped for a permit renewal. Spanos said that “clarifying language” about nitrogen has been added to permit renewals in New Hampshire, Massachusetts and Vermont since 2009, due to concerns about communities in those states discharging treated wastewater into the Connecticut River, which then flows out into Long Island Sound.

Kulbacki said stricter nitrogen limits in Hanover’s permit would “drastically affect us more than the development (on Route 120).”

“The problem with that piece is that the regulation has to be based on science, there are some politics involved with this,” said Kulbacki, who added that different nitrogen limits would necessitate different improvements to the treatment facility.

The limits, Kulbacki said, could mean the difference between a wastewater treatment facility upgrade ranging from $1 million to $3 million, or an upgrade ranging from $30 million to $40 million. Depending on how the scenario unfolds, the town could view the intake of Lebanon wastewater in a different light.

“If we eliminated flow, could we meet those limits?” Kulbacki asked. “We don’t know that until we see the number. That’s really the wildcard.”

Lebanon’s Backup Plan

According to its agreement with Hanover, Lebanon would have five years to put a contingency plan in place and redirect all Hanover-bound wastewater to its own treatment facility, located along the Connecticut River in downtown West Lebanon.

Mike Lavalla, Lebanon’s public works director, said the city would have enough time to engineer pump stations and redirect wastewater down to existing sewer infrastructure in the southern portion of the Route 120 corridor that leads to the Lebanon plant.

“If Hanover ever did get to the point where, for whatever reason, they could no longer accept either above a certain threshold or accept any of our waste, yes, we’ve got the window of time to develop a plan to move it into our system,” he said.

But Kulbacki said the solution might not be that simple for Lebanon.

“It’s not just getting it there,” he said “One you get it there, what do you do with it? If they suddenly had 600,000 more gallons, I think there would be some problems with their plant.”

Don Schagen, superintendent of the Lebanon wastewater treatment facility, said the plant is designed to have a capacity of 3.2 million gallons a day. He said it now uses about 1.8 million gallons a day.

Lebanon has authorized about $10.7 million in upgrades to its wastewater treatment facility to be installed in the next two years but paid for over the next two decades. The upgrades, however, address treatment processes and do not expand the plant’s capacity.

Lavalla said that, as far as he knows, the plant does not have a “capacity issue.” But given the uncertainty surrounding potential flow levels, he said, it is difficult to predict when one might be required.

The wastewater management relationship between Lebanon and Hanover is mutually beneficial, as Hanover relies on revenue from Lebanon to keep its sewer rates reasonably low. Hanover receives $350,000 to $400,000 annually for treating wastewater from Lebanon customers, according to Kulbacki.

“The double-edged sword is, because they’re such a large customer base, if we were to (stop accepting Lebanon’s flows), we’d lose that revenue base and would have to pass that loss along to Hanover residents,” said MacLean. “I don’t see them willing to accept a 5 percent increase in their sewer rate.”

The Lebanon customers who send wastewater to Hanover are still billed by Lebanon. The city then pays Hanover based on the town’s lower wastewater collection fees, but Len Jarvi, Lebanon’s finance director, said the leftover revenue is needed to maintain and operate the wastewater infrastructure that sends the sewage to Hanover’s treatment plant.

Kulbacki also emphasized that Lebanon’s wastewater flow provides an economic benefit to the town of Hanover. “It doesn’t make sense for us not to take it when we can take it,” he said. But Kulbacki said there is an additional layer for Hanover public works officials to consider when allocating capacity, in that using more capacity brings with it “more strings and more requirements” from environmental regulators.

“Any time you increase that flow, your flows get looked at closer and closer,” he said. “What is insignificant in a small plant, those are the sort of things you start seeing as you get bigger and bigger.”

A Regional Approach

In planning for the future, Lebanon officials mentioned the possibility of requiring more efficient water and sewage systems for new development in the corridor, and some have even been murmuring about the possibility of “regionalization.”

Gast-Bray, the planning director in Lebanon, said regionalization is a “discussion that we’re trying to bring about.”

“That way, when the (Environmental Protection Agency) comes forward and changes their regulations, then there’s a way to get (the communities) to work together,” he said.

City Councilor Nicole Cormen brought up the possibility of a regional water and sewer district, or some sort of cooperative, but said that raises the question of the city maintaining control over its own development.

“When you share the cost, people want to share control, and that’s fair,” said Cormen. “Is Lebanon willing to give up some control? I’m not sure that we would want to, because we have already been so much affected by external pressure, when I think we as a city probably could have asserted ourselves better.”

Gail Dahlstrom, vice president of facilities management at Dartmouth-Hitchcock, said regional utility districts exist in many other parts of the country, and such a district makes sense for the Gile watershed in Lebanon “from a practical, logistical perspective.”

“This somewhat arbitrary municipal line colors the conversations in a way that’s unfortunate,” said Dahlstrom. “I think it’s troubling and will require a significant amount of effort.”